Caroline Maria Vaughan v. Nathaniel Thomas Caylor, 75377-1

Carrie (Caroline) Vaughan and Nathaniel Caylor are divorced parents of one child; a February 2016 contempt finding determined Vaughan violated the parenting plan by unilateral decisionmaking and interfering with Caylor's access to information.
The superior court set a review hearing for May 24, 2016; Caylor filed a new contempt motion alleging further unilateral decisionmaking, which the court denied.
At the May review hearing the court found Vaughan had failed to purge the February contempt and awarded Caylor $4,500 in attorney fees and costs.
Caylor submitted counsel declarations describing qualifications, 12 hours of work, and the requested hourly rate; the trial court awarded fees but issued only cursory findings stating the fees were reasonable and that specificity under a Berryman analysis was provided.
Vaughan appealed, challenging the sufficiency of the trial court’s findings supporting the attorney fee award; both parties requested appellate fees.
The Court of Appeals concluded the record lacks adequate findings explaining the fee award and remanded for entry of findings and conclusions; it denied appellate fee requests to both parties.

Issue	Vaughan's Argument	Caylor's Argument	Held
Appealability of order	Implicitly that order is appealable as final	Argued not appealable under RAP 2.2 (not briefed)	Court declined to resolve Caylor’s contention; treated appeal as proceeding without deciding appealability
Reasonableness of attorney fees	Trial court abused discretion because findings are inadequate to show lodestar analysis and considerations required by Berryman	Trial court relied on counsel declarations and argued fees were supported	Court held counsel’s declarations provided a basis for lodestar but trial court’s findings were too conclusory; remand for specific findings and conclusions to explain fee award
Adequacy of trial-court findings	Findings insufficient to show hours, rate, or Berryman factors	Trial court’s single finding asserting sufficient specificity under Berryman	Court held that single finding was inadequate for meaningful review and ordered remand for proper findings
Appellate fees request	Vaughan sought fees under RCW 26.09.140 (financial need) and on basis of Caylor’s alleged intransigence	Caylor sought fees under RAP 18.9 for frivolous appeal	Court denied both: Vaughan failed to provide RAP 18.1(c) affidavit and offered no evidence of intransigence; Caylor’s frivolous-appeal claim failed because Vaughan’s challenge succeeded

In re Estates of Smaldino, 151 Wn. App. 356, 212 P.3d 579 (discusses when a contempt show-cause order is appealable)
In re Marriage of Wagner, 111 Wn. App. 9, 44 P.3d 860 (contempt/appealability principles)
Berryman v. Metcalf, 177 Wn. App. 644, 312 P.3d 745 (trial courts must make meaningful findings when awarding attorney fees and perform independent reasonableness analysis)
Bowers v. Transamerica Title Ins. Co., 100 Wn.2d 581, 675 P.2d 193 (standards for fee awards and findings)
224 Westlake, LLC v. Engstrom Props., LLC, 169 Wn. App. 700, 281 P.3d 693 (party seeking fees must provide reasonable documentation)
In re Marriage of Crosetto, 82 Wn. App. 545, 918 P.2d 954 (remand for inadequate fee findings)
In re Marriage of Mattson, 95 Wn. App. 592, 976 P.2d 157 (intransigence as basis for fee awards)
In re Marriage of Wixom, 190 Wn. App. 719, 360 P.3d 960 (definition of frivolous appeal in family-law context)